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2018 GROUNDWATER MONITORING REPORT , <br /> Between 2005 and 2017, an average of approximately 10,000 tons of bypass dust was placed in the CKD <br /> disposal area each year. <br /> In 2001,with the construction of the dry kiln, a pug mill was installed to add water to the bypass dust prior , <br /> to transporting the bypass dust to the CKD disposal area in the quarry, in order to reduce dust emissions. <br /> With the addition of the pug mill, Holcim discontinued the use of sludge from the Fremont Sanitation <br /> District WWTP for dust control. <br /> Bypass dust is currently disposed of in a previously mined section (cut)of the limestone quarry to the <br /> south of former monitoring well MW-10. The locations of cuts previously used for CKD disposal are , <br /> indicated on Figure 2. The bottoms of these cuts coincide with the top of the underlying Codell <br /> Sandstone,which is the primary water-bearing unit in the quarry area. To prevent contact of CKD and <br /> bypass dust with this groundwater, approximately 10 feet of shale was backfilled and compacted in the <br /> bottom of these cuts prior to placement of CKD and bypass dust. The site geology and hydrogeology are <br /> described in the Groundwater Monitoring Plan (GMP; Blasland, Bouck&Lee, Inc. [BBL]2002). <br /> 1.3 Site Regulatory History <br /> In Colorado, the DRMS is responsible for regulating CKD and bypass dust disposal. Therefore, the <br /> requirements for CKD and bypass dust management are incorporated into each facility's Mined Land <br /> Reclamation Permit. The plant is permitted to dispose of CKD and bypass dust(although CKD is no <br /> longer generated by the plant) in the quarry under State of Colorado Mining Permit No. M-77-344 <br /> (permit). Specific requirements for protection of groundwater are described in Rule 3.1.7(7)(i)through (viii) <br /> of the Construction Material Rules and Regulations(Mined Land Reclamation Board [MLRB]2001)and <br /> the Colorado Department of Public Health and Environment(CDPHE), Water Quality Control Commission , <br /> (WQCC)Regulation No. 41, Basic Standards for Ground Water(CDPHE 2008). <br /> It was recently communicated to Holcim by the WQCC that the regulatory requirements established for <br /> the site as determined by the DRMS may no longer be relevant. Because Holcim only recently received ' <br /> this communication and no official policy has been established, in the interest of submitting this report in a <br /> timely manner, it was prepared to summarize the data as it relates to the previously established <br /> regulations and NPLs. The WQCC has indicated that they would be willing to review the data obtained to <br /> date as it compares to WQCC Regulation No. 41 and provide guidance to any additional data that may be <br /> required. <br /> 1.3.1 Baseline Groundwater Monitoring Program ' <br /> On August 16, 1999, Holcim submitted a request to the DRMS for a Mine Permit Technical Revision TR- <br /> 06(TR-06)to its permit for the disposal of CKD in previously mined areas at the quarry(K-S &Company <br /> 1999). TR-06 describes the CKD disposal procedures and facilities, a closure plan for the disposal areas, <br /> erosion control measures used at the site, CKD sampling and analysis, and hydrogeologic conditions at ' <br /> the site. The DRMS, formerly the Division of Minerals and Geology(DMG), reviewed TR-06 and <br /> responded with an initial adequacy review letter on January 18, 2000 (DMG 2000). On behalf of Holcim, <br /> K-S&Company submitted responses to DMG's adequacy review letter in May 2001 (Holnam 2001). The <br /> DMG responded with a second adequacy review letter on October 22, 2002 (DMG 2002). <br /> -"M 2 ' <br />